How to Create an OSHA-Compliant Training Program

OSHA requires all contractors, residential or commercial, to have a written safety program. Many residential contractors balk at this, but it’s the law, and a written plan could save you a lot of trouble if OSHA pays you a visit.

Writing a safety plan requires some basic knowledge, however, and the best place to get that knowledge is at OSHA 30 training: a 30-hour class for company owners and job supervisors that cover the entire range of OSHA requirements.

Here are the steps required to refine your safety program.

1. Demonstrate management commitment. Start by showing that you take safety seriously. A good first step is to identify a company safety manager, usually the person who attended the OSHA class.

2. Do a hazard assessment. Identify typical hazards that your workers encounter on jobsites, and detail how you will protect them from each hazard.

Let’s say you build additions. Hazards include the danger of falls when framing and roofing, and the risk of electric shock when working with power tools. You can address the fall hazard with conventional fall protection and the shock risk with a protocol for ensuring tools are grounded.

If you perform demolition on pre-1978 homes, you need a plan for protecting workers from lead dust. This will include giving them a baseline lead test, having them cleared by a physician to wear a respirator, and providing respirator training.

3. Put resources into place. The plan should certify that you have basic health and safety items on every job. These can range from harnesses and anchor lines for roofing to respirators, safety glasses and gloves for work around dust and chemicals. OSHA also requires that each jobsite have a fire extinguisher, drinking water, a hand- and face-washing station, a place to go to the bathroom, a first aid kit, and someone certified in basic first aid. There also needs to be an evacuation plan.

4. Write a PPE plan. OSHA requires that employers provide a written plan for personal protective equipment. Prior to use of PPE, employees must be trained on how to inspect, use, and maintain equipment provided for their protection. Training must be certified and documented. 

5. Arrange for training. Many OSHA standards require employee training. For example, 29 CFR 1926.501 Subpart M (“Duty to Have Fall Protection”) says that employers need a fall protection training program, along with documentation that all employees were trained.

6. Define how you will report injuries. In your safety program accident reporting section, identify who will be responsible for taking charge of emergency actions and the follow up protocol. The plan should include accident investigation and follow up documentation.  

The above is only a surface overview. For deeper dive go online to OSHA’s Compliance Assistance Quick Start page.

All of this can seem overwhelming, but it doesn’t have to add a lot of time or cost. Once your crews get used to working with the plan it stops being a big deal. I recently taught an OSHA 30 class with several commercial contractors and one residential contractor. The residential contractor freaked out at the requirements. The commercial guys? Their reaction was, “Yeah, it all makes sense.”